2021 RETA Breeze May-June

TIER II REPORTING & AVOIDING COMMON MISTAKES PART 2 By: Travis Weber, SCS Engineers T he first , and most obvious, error is simply a failure to complete the Tier II Report by the deadline, or failing to complete it altogether. This may the facility CMMS, should you be lucky enough to have one, is often a better approach. However, be careful that the work order is not automatically assigned

In part one of this article, we spent some time reviewing the background and basic requirements of EPCRA Tier II Reporting, as well as evaluating some of the factors that determine how reporting can be completed in your respective state. In this article, we will take a look at some ideas to help avoid some of the more common errors associated with Tier II Reporting.

seem like an unlikely occurrence (and hopefully it is for you). However, Tier II Reporting is something that can be lost in the shuffle of tasks that make up a busy calendar for a compliance professional. The annual Tier II Reporting deadline of March 1st (unless otherwise directed by your state) should be tracked in some manner to ensure that it does not sneak up on you, or you completely forget about it. This can be done by entering recurring tasks in your personal calendar or into a computerized maintenance management system (CMMS), so that reminders are generated as you approach the submittal deadline. The downside to using a personal calendar is that it is ineffective if the person leaves. Perhaps the individual who had been responsible for Tier II Reporting has retired or maybe they no longer work at the facility. For this reason, a recurring work order built into

to specific personnel. Much like the personal calendar, if they leave the company and their duties were not properly reassigned, the work order may become frozen in cyberspace, so to speak. This is a common cause for a facility failing to complete their annual Tier II Report. Other common mistakes that occur are related to chemical inventories. The chemical inventory of your facility is something that may vary greatly depending upon the type of facility and associated processes. For example, a cold storage facility is typically going to have fewer chemicals that need to be reported in their chemical inventory than a food and beverage processing plant. This is often due to the large quantities of “clean-in-place” or CIP chemicals that are used and stored at food and beverage processing plants. Regardless of the size

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